March 6th 2026
Dear Ministers
We write to you today, as the recognised steering group for the professional driver training industry, to express our ongoing concern over the effective barring of driving instructors from the practical test booking platform and reiterate our concern at the manner in which the consultation that informed this decision was conducted.
Approved Driving Instructors should play a key role in helping to gatekeep a driving licence, helping to ensure that only those ready to drive independently proceed to the practical driving test stage. Indeed, one would expect that having a system which requires a regulatory license to deliver driver training would imply that trainers actually played such a crucial gatekeeper role. However, in reality, we must recognise that this is a questionable regime, as trainers do indeed require a licence to teach, but if you want a driving licence in the UK, you can learn to drive with anyone who has held a full licence for three years and is over the age of 21.
So, we already have a clear challenge in the learning to drive process in that Learners can learn whatever they want (due to a lack of a concrete curriculum of learning to drive), learn with almost whoever they want, and go to the test centre whenever they feel they’re ready to drive on their own, after they’ve taken a theory test. A very simplistic way of looking at it admittedly, and whilst acknowledging the average learner will undertake at least some training with an ADI, as DVSA collects very little solid data on pupils during the learning process (let’s be honest, the average number of hours a learner undertakes in the UK is derived from an occasional survey, sometimes under duress at the end of a practical test, and isn’t a result of any consistent tracking of the majority of pupils, which should be perfectly feasible to deliver in a licensing regime where all pupils have to pass through formal gateposts, where there is ample opportunity to collect better data) it really isn’t a perfect science in terms of knowing what people are learning, for how long and with whom. And at the heart of it, we appear to have engineered a system which favours pupil and parent wants, versus road safety needs.
Now, with effectively blocking ADIs out of the booking platform, we have further removed what should be the professional gatekeeper’s ability to identify when a pupil should move to test stage and access a driving licence, enabled even more Learner and inexpert decision-maker choice, and engineered in potentially more risk. Before this decision, due to the core issue of test waiting times (i.e. a lack of test supply), trainers were already facing pressure from pupils and parents to get them test ready and keep them test ready, as well as get the pupil ready to leap for any test the pupil randomly managed to grab in the system – whether they were ready for that test or not (because, consumer choice again – let the Learner driver choose when they’re ready to take a test and let a driving test slot be used to be that gauge…when we could actually better use a licenced professional to be that gauge). And if a trainer could not, or would not, take a pupil for test on the day the pupil had booked it, the pupil would simply try and find a trainer, licenced or unlicenced, they had never used before (and who has no knowledge of that pupil’s ability) or go in their own car – as evidenced by the rise in private runners on test in the last 5 years. And now? Well, we’ve decided that the (in practice) low risk of an actual ADI being a bad actor in the booking system is far worse than the risk of the inexpert and inexperienced pupil deciding when they should take a driving test and get a driving licence. By the way, we recently asked about the risk profile of private runners on test and were told that they didn’t really present a significant issue – but perhaps that is because DVSA Examiners themselves have told us of an unofficial policy of deliberately exposing those private runner candidates to less risky routes…
Not only (using this sledge hammer to crack a nut approach move to block trainers from the booking platform, penalising the majority for the actions of a tiny minority) have we potentially engineered more risk into the system and onto our roads, the decision has also had the, perhaps unintended, consequence of lumping ADIs in with third-party bad actors in the booking system, further disenfranchising ADIs at a time when their trust and confidence in the agency is at a low. Couple that with communications campaigns telling trainers to ensure their pupils are test-ready before they book a test, and then arguably taking away a trainer’s real ability to police that, and you can see why the profession is unhappy with this decision. And as insiders (unlike the seemingly easily duped public stakeholder) this stakeholder doesn’t easily buy bad actors in the booking system being a) a significant number of ADIs at all and b) the core issue behind test waiting times, when we know failed Examiner recruitment and other failures in test resourcing, continue to be the critical issues, so heralding blocking trainers from the system as a ‘fix’ here (harming trainers, and potentially novice and wider road user safety) has not gone down well in the industry.
In addition, the industry feels the manner in which the consultation itself was conducted (and the swift decision to change in policy) is also challengeable. As one stakeholder commented, in the unsurprisingly tense stakeholder meeting that had to be called after the mishandled announcement of the change, this was a referendum not a consultation, yet it was billed as a consultation. Challenges around how the responses of the non-expert, non-educated public consumer – who it was entirely predictable were going to ‘vote’ for what they wanted (versus what they needed to be safe drivers) – would be balanced against the much smaller voice of the licenced, expert professional trainer were effectively dismissed in the lead up to the consultation. Causing further concern was when NASP voiced the same concerns post-consultation, and asked how balance had truly been struck in decision-making, DVSA questioned why we’d never raised the issue before or during the consultation period. The reality is we did raise those concerns, they are minuted (from the joint NASP/DVSA meeting we raised them in) and we still don’t have a satisfactory response on these challenges. Nor have we seen an output evaluation from the entire consultation that demonstrates how the risks of the decision to close out
trainers from the booking system have been fully evaluated before policy changes were made. We do respect that a current consultation on Minimum Learning Periods will allow some opportunity for the role of ADIs as professional gatekeepers to be properly considered. However, even in this proposal, the role of the non-professional is apparently being snuck in with the suggestion that any accompanying driver could sign off these hours, which is effectively Einstein’s definition of madness when it comes to the scenario of just letting anyone be part of ‘training’ Learners to drive and gatekeeping their access to a driving licence. You are fundamentally promoting the role of a novice (when it comes to driver education, a driver without being a driver trainer is a novice when it comes to driver training) being a pivotal part of training a novice – and you see no issue with that? The issue is, yet again, prioritising ease of access to a licence for the driver over road safety risks to all.
For all the reasons above, we ask again that Ministers answer to the profession as to whether the long-term impact of the decision to further disenfranchise Approved Driving Instructors (because that’s what blocking them from the booking system is doing in reality) has truly been considered, and adequately weighed. The feeling of the licenced, DVSA fee-paying driver training professional is that this wasn’t a fair consultation, and that the results weigh unfairly on ADIs (certainly some have left the industry as a result, and intensive driving schools have suffered a huge impact on their business). More importantly, there are genuine concerns that this prioritisation of pupil choice over road safety may have far-reaching, and potentially dangerous consequences. We end in adding that the results released this month from the Working as a Driving Instructor Survey seem to lend even more weight to our arguments. We respect that DVSA have recently held a webinar to reassure trainers about the implementation of these changes (and that the Car Driver Forum has also discussed the change) but, as the key representative channel for the profession, we still do not have enough comfort that this decision has been fully thought through in terms of what could be a dangerous and ultimately counter-productive end-game.
Yours sincerely,
On behalf of the National Associations Strategic Partnership
Carly Brookfield
Driving Instructors Association
Peter Harvey
Motor Schools Association
Stewart Lochrie
Approved Driving Instructors National Joint Council
